New edition released of transfer pricing guidelines for multinational enterprises and tax administrations
The new guidelines (see here) contain novel elements stemming from conclusions reached in the context of the BEPS Project and work of the OECD/G20 Inclusive Framework.
The OECD’s transfer pricing guidelines provide essential guidance on the application of the arm’s length principle, which is the international consensus on the valuation for tax purposes of cross-border transactions between companies in multinational groups.
The new 2022 edition of the guidelines includes novel elements on:
Revised application of the transactional profit method.
Guidance for tax authorities on hard-to-value intangibles.
Valuation of financial transactions.
Amendments have also been added with the intention of providing greater consistency and clarity to the treatment of controlled transactions.